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Home My WebLink About06-6798 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL 1:I'.'ISICN CAC:I, LLC Plaintiff No: Ots? 1 ^ Ce/ 9P l-.1 U t C ?Q„ COMPLAINT IN CIVIL ACTION JER;ZY B SWANGER Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THLS PARTY: James C. Warmbrodt,4252,I WELTMAN, '11EINBERG Sc REIa CO., L.P.A. 435 Seventh Avenue, Sure 2718 Pi,.tsburglh, PA 15219 (41.2) 434-7955 FA`;: 412-338-7130 05.'81697 C E Pit SGM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC Plaintif f vs. Civil Action No GEi2RY B SWANGER Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. IL you wash to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing wit'n the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, 330 TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CA-.,I GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A ;-,AWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT' AGENCIES THAT MAY OFFER LEGAL aER',IICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 I COMPLA I:NT 1. Plaintiff, CACH, LLC is a corporation with offices at 370 17TH ST.,SUITE 5000 DENVER , CO 80202 . 2. Defendant is adult individual(s) residing at the address listed below: GERRY B SWANGER 24 E ORANGE ST SHIPPENSBURG, PA 17257 3. Defendant applied for and received a credit card bearing the account number 5491000846477748 . 4. Defendant made use of said credit card and has a current balance due of $3804.17 , as of September 14, 2006 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 6.030. per annum on the unpaid balance from September 14, 2006 . A co:y of Plaintiff's STATEMENT is attached hereto, marked as Exhibit 11111 and made a part hereof. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant , GERRY B SWANGER , INDIVIDUALLY , in the amount of $3804.17 with continuing interest thereon at the rate of 6.000,5 per annum from September 14, 2006 plus costs. James War odt,42524 WELT WEINBERG & REIS CO., L.P.A. =36 ev th Avenue, Suite 2718 -it sbu gh, PA 15219 (4 ) 34-7955 F 12-338-7130 0 2 697 C E Pit SGM This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. I { GERRY B SWANGER Account Number. 6491 0008 4647 7748 Your Bank of America MasterCard@ Account New Balance $2.938.35 Past Bus Amount IN" nn Total Credit Una $0.00 Available Credit $0.00 Cash Umk $0.00 Available Cash $0.00 Ovw lmk Amount $0.00 EWWV Date W 4105 Minimum Payment Due $2,938.35 Paynwtt Due Date 05/pgp5 24-Hour Customer Swfte 1.800.492.2500 Pay onlinei visR For Lost or Sbw Cards 1.8w.848.8090 www.banlWwwrica.com Transactions view rsant tramw*ns and pry your bill online at www.bankofamerke wn. POST. TRANS. REF. DATE DATE NO. DESCRIPTION AMOUNT CR-CREW Apr 13 Ap?13 LATE PAYMENT FIE $3&00 Apr 14 Apr 14 PURCHASE FIN CHO CREDIT CR $530.44 Apr 14 Apr 14 LATE FIE CREW CR $338.42 Apr 14 Apr 14 OVERUMIT FEE CREDIT CR $123,97 Apr 14 Apr 14 PERIODIC FWANCE CHARGE 581.93 Account Summary Previous Balance $3,814.25 Purchases + $0.00 Cash Advances + $0.00 Other Dal ft + 535.00 Credits 599283 FINANCE CHARGE + $81.93 Payments - $0.00 New 9alarm = $2,938.35 Past Due Arnount $522.00 Finance Charae Summary APR Pilr6lc Rata ' ' 11do;(A ADd) ._... Pariod'p(P) Charge Purchases 28.990% 0.07394%v 0 $3.820.97 $81.93 P Cash 28.99096 0.07394%v D 50.00 $0.00 P ANNUAL PERCENTAGE RATE 20.990% -Variable Your awwrrt has charged off and has been referred to our Recovery Department. Please call 1.800.888.7011 to maks Immediate arraltpemsnt, Bank of America -W BankefAmorica -490' Customer Career EXHIBIT 0020000 0293835 0293835 SM000846477748 BANK OF AMERICA NEWARK BOX 1NJo 07101-1070 lllurlr„inrlillrun,Iln,lllhulurillrnlnrllluullul snt Coupon Account Number 3491 0008 4847 7748 Payrrrant Due Date 05A) m TOW Kmhwrn Payment Due $2.0835 New Balance: fZ,938.33 v,? ? 6cp 2 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA C.S. 4904 relating to unsworn falsifications to authorities that she is Dawn Rannells, Authorized Agent of CACH, LLC, plaintiff herein, that she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of her knowledge, information and belief. Z Dawn Rannells This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. WWR# "- fJ itt^? • b ? ? rv CO F 'IN SHERIFF'S RETURN - NOT FOUND -- • \ i w CASE NO: 2006-06798 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CACH LLC VS SWANGER GERRY B R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT SWANGER GERRY B but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT 24 E ORANGE STREET , SWANGER GERRY B NOT FOUND , as to SHIPPENSBURG, PA 17257 ALTHOUGH NUMEROUS ATTEMPTS WERE MADE, WE WERE UNABLE TO SERVED DEFENDANT AT GIVEN ADDRESS. Sheriff's Costs: Docketing 18.00 Service 52.80 Not Found 5.00 Surcharge 10.00 .00 s(l?Cle 1 v 85.80 So answer` R. Thoma Kline Sheriff of Cumber arid-County WELTMAN WEINBERG REIS 12/28/2006 Sworn and Subscribed to before me this day of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC Plaintiff vs. GERRY B SWANGER Defendant No. 06-6798 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C WARMBRODT, ESQUIRE PA I.D. #42524 WELTMAN, WEINBERG & REIS, CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05281697 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC Plaintiff vs. Civil Action No. 06-6798 CIVIL TERM GERRY B SWANGER Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: RMBRODT, ESQUIRE PA I.4 WELWEINBERG & REIS CO., L.P.A. JAME)venue 2718 Building 436 Pitt 15219 (4 ) #05281697 b ' rn ca Ul -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC Plaintiff vs. GERRY B SWANGER Defendant No. 06-6798-CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C WARMBRODT, ESQUIRE PA I.D. #42524 WELTMAN, WEINBERG & REIS, CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5281697 { 4 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC Plaintiff VS. Civil Action No. 06-6798-CIVIL TERM GERRY B SWANGER Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: JAMES C R PA I.D. # 5 WEL N, INB 2718 K pper Buildir. 436 S ent Avenue Pitts gh A 15219 (41 43 -7955 , ESQUIRE & REIS CO., L.P.A. WWR #5281697 o C) ra r°a 3 co SHERIFF'S RETURN - REGULAR CASE NO: 2006-06798 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACH LLC VS SWANGER GERRY B KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SWANGER GERRY B the DEFENDANT , at 1935:00 HOURS, on the 12th day of October , 2007 at 100 DYKEMAN ROAD SHIPPENSBURG, PA 17257 by handing to GERRY SWANGER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 38.40 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 101010,7 66.40 10/15/2007 WELTMAN WEINBERG REIS Sworn and Subscibed to By: before me this day of A.D. A %1- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC Plaintiff No. 06-6798-CIVIL TERM vs. PRAECIPE TO SETTLE, DISCONTINUE AND END WITH PREJUDICE GERRY B SWANGER Defendant FILED ON BEHALF O Plaintiff COUNSEL OF RECO OF THIS PARTY: PATRICK THOMAS WOODMAN, ESQUIRE PA I.D #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5281697 { ,y J? I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC Plaintiff VS. Civil Action No. 06-6798-CIVIL TERM GERRY B SWANGER Defendant PRAECIPE TO SETTLE DISCONTINUE AND END WITH PREDJUDICE TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue the above captioned matter upon the records of the Court with prejudice and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: nvJJQ-' VVW PATRICK THOMAS N PA I.D #34507 WELTMAN, WEINBE 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5281697 Sworn to and subscribed Before me the "2"Z y of JANUA Y 200 r i 1 ARY PUB -NNSYLV,,. Notarial Seal Heidi J. Kelly, Notary Public City Of Pittsburgh, AA M ission Emoi y Courity My Comm res Nov. 4, 2009 ember. Pennsylvanla Asso?!? -? at r .. ESQUIRE & REIS CO., L.P.A. C7 7 mr C xti trn